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EPA Needs Better 

Management of Personal 

Property in Warehouses

Report No. 15-P-0033 December 8, 2014

 

U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

Spending Taxpayer Dollars
Report Contributors: Robert Adachi

Angela Bennett

Melinda Burks

Andres Calderon

Safiya Chambers

Debra Coffel

Kevin Collins

Teren Crawford

Nancy Dao

Mike D. Davis

Kevin Haas

Iantha Maness

Leah Nikaidoh

Denise Patten

John Trefry

Abbreviations

EPA U.S. Environmental Protection Agency

GAO Government Accountability Office

GSA General Services Administration

OARM Office of Administration and Resources Management

OIG Office of Inspector General

OMB Office of Management and Budget

RTP Research Triangle Park

Cover photo: Photo of the inside of the V Street warehouse in Washington, D.C.

(EPA OIG photo)

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 15-P-0033

December 8, 2014

Why We Did This Review

Based on Office of Inspector 

General (OIG) concerns, 

we conducted an audit to 

determine the extent to which 

personal property—any 

property except real property—

stored in warehouse space is 

effectively utilized, accounted 

for and disposed of by the 

U.S. Environmental Protection 

Agency (EPA).

The OIG issued the following 

early warning reports related to 

this audit:

 Main EPA Headquarters 

Warehouse in Landover, 

Maryland, Requires 

Immediate EPA Attention, 

May 2013.

 National Service Center for 

Environmental Publications 

in Blue Ash, Ohio, Spent 

$1.5 Million to Store 

Excess Publications, 

March 2014.

This report addresses the 

following EPA goal or 

cross-agency strategy:

 Embracing EPA as a highperforming organization.

Send all inquiries to our public

affairs office at (202) 566-2391

or visit www.epa.gov/oig.

The full report is at:

www.epa.gov/oig/reports/2014/ 

20141208-15-P-0033.pdf

 

EPA Needs Better Management of 

Personal Property in Warehouses

 What We Found

The EPA did not adequately inventory property nor 

provide adequate oversight to ensure effective and 

efficient use of EPA resources. Specifically, the EPA:

 Did not have policies to account for its 

non-accountable and non-sensitive personal 

property.

 Did not maintain annual physical inventories of 

personal property.

 Did not follow a requirement to inventory and track all electronic property. 

 Inventoried personal property in a separate, manual system rather than in its 

official inventory system.

Also, the EPA did not establish effective and efficient controls for its property 

stored at its warehouse facilities. Specifically, the EPA:

 Did not timely excess or dispose of property.

 Did not sufficiently utilize warehouse space to store property.

 Unnecessarily stored items that were readily available for purchase locally 

or did not fulfill an immediate need.

 Did not prevent the unauthorized use of government property.

The EPA did not implement effective oversight and controls to ensure efficient 

use of stored EPA property. Though the EPA contracted for almost $50 million for 

warehouse management at the eight facilities we reviewed, it has incomplete 

information, which impairs its ability to safeguard property against theft, loss, 

waste and mismanagement.

 Recommendations and Planned Corrective Actions

We recommend that the EPA update policies to inventory non-accountable and 

all electronic property, have the same inventory management system for all 

property stored, and reconcile annual physical inventory counts against its 

inventory system records for all personal property. Additionally, we recommend 

that the EPA optimize space, improve property storage procedures, and address 

oversight and accountability.

The agency agreed with our recommendations and provided corrective actions 

with estimated completion dates. All of the nine recommendations we made are 

resolved and corrective actions are completed or ongoing. 

U.S. Environmental Protection Agency

Office of Inspector General

At a Glance

Monetary benefits 

totaling $8.9 million can 

be achieved by the EPA 

through improved 

warehouse 

management of 

personal property.
December 8, 2014

MEMORANDUM

SUBJECT: EPA Needs Better Management of Personal Property in Warehouses

Report No. 15-P-0033

FROM: Arthur A. Elkins Jr.

TO: Nanci E. Gelb, Acting Assistant Administrator

Office of Administration and Resources Management

This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the 

U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems 

the OIG has identified and corrective actions the OIG recommends. This report represents the opinion of 

the OIG and does not necessarily represent the final EPA position. Final determinations on matters in 

this report will be made by EPA managers in accordance with established audit resolution procedures.

Action Required

In accordance with EPA Manual 2750, your office provided acceptable and complete planned corrective 

actions in response to OIG recommendations. All recommendations are resolved and no final response 

to this report is required.

We will post this report to our website at http://www.epa.gov/oig.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

THE INSPECTOR GENERAL
EPA Needs Better Management of 15-P-0033

Personal Property in Warehouses

Table of Contents

Chapters

1 Introduction ...................................................................................................... 1

Purpose ..................................................................................................... 1

Background................................................................................................ 1

Responsible Offices ................................................................................... 2

Noteworthy Achievements ......................................................................... 2

Scope and Methodology ............................................................................ 3

Other Prior EPA OIG Reports .................................................................... 4

2 Incomplete and Inaccurate Inventories........................................................... 6

EPA Did Not Adequately Inventory Property .............................................. 6

Conclusion .......................................................................................... 9

Recommendation ................................................................................. 10

Agency Comments and OIG Evaluation..................................................... 10

3 Inefficient and Ineffective Property Storage and Management ..................... 11

Better Property Storage and Management Needed.................................... 11

Conclusion .......................................................................................... 15

Recommendations..................................................................................... 16

Agency Comments and OIG Evaluation..................................................... 17

Status of Recommendations and Potential Monetary Benefits ............................. 18

Appendices

A Details on Noteworthy Achievements............................................................. 20

B Summary on Facilities Reviewed .................................................................... 21

C Agency Response to Draft Report................................................................... 25

D Distribution ....................................................................................................... 32
15-P-0033 1

Chapter 1

Introduction

Purpose

The U.S. Environmental Protection Agency’s (EPA’s) Office of Inspector 

General (OIG) planned to conduct a review to determine whether the EPA 

disposed of excess computers in compliance with government rules and 

regulations. Other OIG work related to contractor activities identified concerns 

related to EPA personal property stored in warehouses. Consequently, we 

increased our original plans to include all EPA property stored in warehouses.

The objective of this audit was to determine the extent to which the EPA’s

personal property is stored in select warehouses/storage spaces and is effectively 

utilized, accounted for and disposed of by the EPA.

Background

The Federal Property and Administrative Services Act of 1949 states that each 

executive agency shall:

 Maintain adequate inventory controls and accountability systems for 

property under its control.

 Survey its property continuously to determine which is excess to its needs 

and promptly report excess property.

 Perform the care and handling of such excess property.

 Transfer or dispose of such property as promptly as possible in accordance 

with authority delegated and regulations prescribed by the General 

Services Administration (GSA).

The EPA Personal Property Policy and Procedures Manual defines personal 

property as any property except real property.

During a prior OIG audit of the Landover, Maryland, warehouse management 

contract, the OIG conducted site visits at this EPA-controlled and contractormanaged warehouse during the period February through April 2013 to address the 

specific audit objective pertaining to contractor costs. The OIG staff found

potential issues concerning the Landover warehouse space. On May 31, 2013, we 

issued Early Warning Report No. 13-P-0272, Main EPA Headquarters Warehouse 

in Landover, Maryland, Requires Immediate EPA Attention.

As part of our review of the EPA’s Cincinnati, Ohio, warehouse, we found that 

the agency stored considerable amounts of publications that far exceeded the 
15-P-0033 2

demand. On March 11, 2014, we issued Early Warning Report No. 14-P-0132,

National Service Center for Environmental Publications in Blue Ash, Ohio, Spent 

$1.5 Million to Store Excess Publications.

Responsible Offices

The following EPA Office of Administration and Resources Management

(OARM) offices/divisions have the following responsibilities:

 Office of Administration−Facilities Management and Services 

Division

 Provides real estate and space management, including: leasing, 

space utilization, disposal of real property, facilities management 

resources analysis, policy development, and contract oversight.

 Manages the property disposal program, and excess re-utilization 

program at headquarters.

 Information Resources Management Division, Cincinnati, Ohio

 Manages the National Center for Environmental Publications and 

Information.

Noteworthy Achievements

The Deputy Administrator issued three memorandums in 2013—dated May 23, 

November 22 and December 20—that identified various corrective actions taken 

by the agency in response to the OIG’s May 2013 early warning report. At the 

Landover warehouse, the agency indicated it inventoried and identified the dollar 

value of furniture, conducted records management training, reviewed and 

disposed of records, sold furniture through GSA in August 2013 for 

approximately $10,000, and released three bays (approximately 40,000 square 

feet at a $442,000 yearly cost avoidance). The EPA also indicated it conducted 

health and safety reviews, removed personally identifiable information and all 

propane tanks, and repaired the facility eyewash stations at the Landover 

warehouse. The Deputy Administrator also ordered an agencywide review of all 

warehouses and storage facilities, as well as a review of agency employee actions,

for potential performance failures and necessary disciplinary actions. 

As a result of the OIG’s March 2014 early warning report on Blue Ash, the 

National Service Center for Environmental Publications recycled more than 

140 tons of material at that warehouse. 

Appendix A provides further details on the actions taken at those two warehouses.
15-P-0033 3

Scope and Methodology

We conducted this performance audit in accordance with generally accepted 

government auditing standards. Those standards require that we plan and perform 

the audit to obtain sufficient, appropriate evidence to provide a reasonable basis 

for our findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

We identified the EPA warehouse and storage facility universe to consist of 

62 facilities with over 500,000 square feet of available storage space.

Table 1: EPA storage and warehouse facilities

Facility title

Items

stored

EPA 

owned

 

Leased

 

Total Sq. ft. Lease costs

Storage Building Vehicles 3 18 21 255,000 $2.6 million

Storage Building Lab/Other 29 5 34 44,000 0.4 million

Warehouses Other 0 7 7 277,000 2.1 million

Subtotal 32 30 62 576,000 $5.1 million

Source: OIG analysis from EPA-provided data as of April 26, 2013.

We conducted the audit from April 2013 to August 2014. As part of the audit, the 

EPA OIG reviewed eight selected warehouses and storage facilities located near 

our field offices and conducted site visits at seven of these locations (see 

Appendix B for details about warehouses and facilities reviewed). The EPA uses 

contractors to manage certain facilities. At the facilities reviewed, the 

management contracts were valued at almost $50 million and included, among 

other tasks, managing warehouse operations, equipment maintenance, mail room 

services and transportation. The square footage, lease and approximate contract 

cost for the eight facilities reviewed in our audit are identified in Table 2.

Table 2: OIG selected storage and warehouse facilities, size and cost

Location

Reported 

sq. ft.

Annual 

lease cost

Annual 

contractor cost1

1 Cincinnati, Ohio 115,000 $558,282 $2,157,388

2 Landover, Maryland 70,000 764,043 1,133,058

3 Research Triangle Park, North Carolina 49,951 372,770 938,098

4 Addison, Texas 22,194 598,114 313,071

5 V Street, Washington, DC 17,501 206,414 533,548

6 Seattle, Washington 7,134 28,101 0 

7 Woburn, Massachusetts 4,500 71,312 515,438

8 Dallas, Texas 6,248 106,341 0 

 Subtotal 292,528 $2,705,377 $5,590,601

Source: OIG analysis from EPA-provided data.

1 Annual contractor cost for managing warehouse operations only.
15-P-0033 4

We received documentation of the progress of the agency’s corrective actions and 

the OIG determined the implementation status of agency recommendations for 

property issues reported in its assurance letters. The OIG obtained contract and 

expenditure information needed to determine potential cost avoidances and 

savings. We reviewed laws, standard operating procedures, GSA’s federal asset

management guidance, Office of Management and Budget (OMB)

memorandums, and the Federal Property and Administrative Services Act to 

determine requirements for utilizing, accounting for and disposing of the EPA’s

personal property. We reviewed agency guidance, policies, procedures, contracts 

and plans related to property and its management. Additionally, we interviewed

staff, including Project Officers, Contract Officer Representatives, Custodial 

Officers and supervisors. We reviewed GSA leases and services provided to the 

agency tenants as they related to storing personal property.

Other Prior EPA OIG Reports

In addition to the two early warning report previously noted, the EPA OIG issued 

the following reports with findings related to the management and storage of 

personal property:

 Report No. 09-P-0233, EPA Did Not Properly Account for All Property 

for Implementing Homeland Security Presidential Directive-12, 

September 15, 2009. Four pieces of property, valued at $29,538, were 

missing and not recorded in the Fixed Assets Subsystem. OIG found 

inaccurate property information recorded in the Fixed Assets Subsystem.

Seven items with incorrect purchase order numbers, property locations or 

acquisition dates were discovered in the system. Furthermore, not all 

property was affixed with an EPA decal number and accounted for in the 

Fixed Assets Subsystem before shipping. There are no open 

recommendations related to personal property in this report.

 Report No. 11-P-0705, EPA’s Contract Oversight and Controls Over 

Personal Computers Need Improvement, September 26, 2011. The EPA 

could not account for 638 computers valued at over $1 million. A senior 

official stated that program offices in accountable areas did not follow the 

property policy during computer deployment. From its internal review, the 

EPA found that numerous unaccounted-for headquarters personal property 

items were transferred without the proper documentation. The EPA did 

not have accurate property data in the Fixed Assets Subsystem. During 

testing, OIG auditors found inconsistencies in the location of personal 

computers, incorrect serial numbers and inaccurate descriptions. OIG 

identified property staff appointed to multiple positions in the same or 

different accountable areas. There are no open recommendations related to 

personal property in this report.
15-P-0033 5

 Report No. 13-1-0054, Audit of EPA’s Fiscal 2012 and 2011 

Consolidated Financial Statements, November 15, 2012.

Report No. 14-1-0039, Audit of EPA’s Fiscal 2013 and 2012 

Consolidated Financial Statements, December 16, 2013.

Report 15-1-0021, Audit of EPA’s Fiscal Years 2014 and 2013 

(Restated) Consolidated Financial Statements, November 17, 2014.

The OIG 2014 report identified that the Compass data system did not 

sufficiently reject personal property information entries that are not 

accurate. As a result, the agency could lose accountability and control over 

property. Auditors identified personal property items for which the 

location was not properly identified, as well as personal property items for 

which the last recorded inventory dates or acquisition dates were in the 

future. The recommendations in Report 13-1-0054 were resolved,

however, issues over internal controls of personal property still exist in the 

most recent audit of fiscal years 2014 and 2013.
15-P-0033 6

Chapter 2

Incomplete and Inaccurate Inventories

The EPA did not adequately inventory property to ensure effective and efficient 

use of EPA resources. Specifically, the EPA:

 Did not have policies to account for its non-accountable and non-sensitive 

personal property. 

 Did not maintain annual physical inventories of personal property at 

25 percent (two of eight) of the facilities reviewed.

 Did not inventory and track all electronic property items as required at 

25 percent (two of eight) of the facilities reviewed. 

 Inventoried courtesy items valued at $38,276 in a separate, manual 

inventory system at 13 percent (one of eight) of the facilities reviewed.

The EPA did not have policies to require that inventory be adequately and 

sufficiently tracked. With incomplete information, the EPA impaired its ability to 

safeguard its assets against theft, loss, waste and mismanagement. 

EPA Did Not Adequately Inventory Property

The Government Accountability Office’s (GAO’s) Standards for Internal 

Controls in the Federal Government states that, “Program managers need both 

operational and financial data to determine whether they are meeting their 

agencies’ strategic and annual performance plans and meeting their goals for 

accountability for effective and efficient use of resources.” The GAO’s

EXECUTIVE GUIDE: Best Practices in Achieving Consistent, Accurate Physical 

Counts of Inventory and Related Property, describes the segregation of duties, a 

commonly used and widely accepted internal control and business practice, for

dividing or segregating key duties and responsibilities among different people.

Implemented effectively, this type of control reduces risk of error and fraud so 

that no single individual can adversely affect the accuracy and integrity of the 

inventory count.

Executive Order 13514, Federal Leadership in Environmental, Energy, and 

Economic Performance, dated October 8, 2009, Section 2, promotes electronics 

stewardship, in particular by employing environmentally sound practices with 

respect to the agency’s disposition of all agency excess or surplus electronic 

products. The National Strategy for Electronic Stewardship, developed by an 

interagency task force on electronics stewardship, recommends that the federal 

government improve tracking of used federal electronics throughout its lifecycle. 
15-P-0033 7

EPA Did Not Have Policies to Account for Its Non-Accountable and 

Non-Sensitive Personal Property

The OIG determined that the EPA did not have policies to account for its nonaccountable and non-sensitive personal property. The agency’s personal property 

manual defines accountable property as “personal property with an acquisition cost 

of $5,000 or more, all leased personal property, certain sensitive items, and 

capitalized personal property with an acquisition cost of $25,000 or more.” 

Non-accountable personal property includes all personal property except that which 

is accountable. The non-accountable personal property in inventory stored at the 

facilities the OIG reviewed included furniture such as desks, chairs and filing 

cabinets, in addition to appliances, systems furniture, letterhead, copy paper and 

file folders. GAO’s Standards for Internal Controls in the Federal Government

indicates that inventories are needed to secure vulnerable assets. EPA’s policies 

required accountable property to be accounted for and tracked but did not address 

accounting for and tracking of non-accountable property. In addition, the EPA did 

not establish effective policy to ensure that its offices and regions adequately and 

sufficiently inventoried all property.

As a result of these conditions, the EPA lacks a complete inventory of its personal 

property, which impairs the EPA’s ability to safeguard its property against theft, 

loss, waste and mismanagement. An example of the EPA’s impairment resulting 

from having incomplete information is a recent OIG purchase. OIG staff 

requested and purchased letterhead for $500 in May 2013. At this time, the 

Landover warehouse had two pallets in stock of OIG letterhead. If the OIG had 

been provided reliable information that the letterhead was stored at the 

warehouse, it would have avoided the unnecessary expense. 

As a result of our May 2013 early warning report, the EPA inventoried 7,978 

pieces of personal property at the Landover warehouse in May 2013 and provided 

information to the Research Triangle Park (RTP) office near Durham, Raleigh and 

Chapel Hill, North Carolina. RTP agency staff indicated they received 

approximately $90,000 of furniture and carpets from the Landover warehouse.

Non-accountable property. (EPA OIG photos)
15-P-0033 8

 

Items shipped from Landover to RTP (left) and boxes of letterhead (right). (EPA OIG photos)

EPA Did Not Maintain Annual Physical Inventories of 

Personal Property as Required

The EPA did not maintain annual physical inventories of personal property at the 

Landover and Cincinnati facilities. The EPA’s policies required annual 

inventories of accountable property. OMB Circular A-123 and the GAO’s

EXECUTIVE GUIDE: Best Practices in Achieving Consistent, Accurate Physical 

Counts of Inventory and Related Property indicated that physical inventory counts 

verify the existence, completeness and accuracy of records. 

One warehouse employee indicated to the OIG that he lacked policy and direction 

from the EPA as to how to inventory property. He stated there was no formal 

policy from the EPA, but a formal policy would result in less confusion about 

expectations concerning inventory and could lead to using best practices 

agencywide. The management contracts at the Landover and Cincinnati facilities

did not require an EPA staff or independent person to be present during physical 

inventory counts. The agency could not provide evidence that physical inventory 

counts had been completed or tracked at its Landover and Cincinnati storage 

facilities, which impairs the EPA’s ability to safeguard its property against theft, 

loss, waste and mismanagement.

EPA Did Not Follow a Requirement to Inventory and Track All 

Electronic Property Items

The EPA did not inventory and track all electronic property items as required at 

25 percent (two of eight) of the facilities reviewed. The OIG observed electronics 

not tracked at the Landover and Cincinnati facilities. In addition, improving 

lifecycle tracking systems for electronic property would provide the opportunity 

to manage the use and disposition of this equipment more efficiently. This would 

also encourage and facilitate environmentally sound use and disposition practices.

Executive Order 13514 promotes environmentally sound practices in the

disposition of all agency excess or surplus electronic products. The National 

Strategy for Electronic Stewardship recommends that the federal government 

improve tracking of used federal electronics. However, the EPA did not have 
15-P-0033 9

policies to require tracking of electronics. Therefore, the agency cannot ensure 

that its electronics are properly accounted for and recycled.

EPA Inventoried Personal Property in a Separate, Manual System

Rather Than in its Official Inventory System

The V Street facility inventoried courtesy property valued at $38,276 in a separate 

and manual inventory system. The agency did not follow its own policies. 

Courtesy property is inventory that should not be stored at a facility but are done 

so as a courtesy. The contract for the V Street warehouse states that all property 

will be recorded using the eCity Warehouse & Inventory Management Software.

The agency’s draft standard operating procedures for its ITS-EPA II contract 

indicates that this system enables the warehouse to properly receive, issue and 

track materials and property purchased by the EPA and the contractor for the 

EPA. Though the EPA required its contractor to enter property into eCity, the 

contractor’s use of a manual system circumvented this control. By not having this

control in place with the use of a manual inventory system, the agency impaired 

its ability to safeguard its property against theft, loss, waste and mismanagement.

A courtesy items manual inventory sheet (left) and some of those items (right).

(EPA OIG photos)

Conclusion

Because the EPA did not inventory non-accountable, non-sensitive and electronic

property items it lacked complete and reliable information, which impaired its

ability to safeguard property against theft, loss, waste and mismanagement. 

By not tracking all electronics, the agency cannot ensure it is accounting for and 

recycling its electronics. The EPA inventoried courtesy items in a separate and 

manual inventory system, but tracking inventory via a manual system leaves the 

system open to manipulation and inaccurate record keeping. Additionally, the 

EPA did not provide adequate oversight over contractor-controlled annual 

inventories to ensure accuracy and completeness.
15-P-0033 10

Recommendation

We recommend that the Assistant Administrator for Administration and 

Resources Management:

1. Update EPA policies to require:

a. An inventory of non-accountable property and all electronics-type 

property in addition to accountable and sensitive property.

b. The EPA to use the same inventory management system for all 

property, including courtesy-stored items along with other personal 

property in the warehouses. 

c. The EPA to reconcile annual physical inventory counts against its 

inventory system records for all personal property.

Agency Comments and OIG Evaluation

The agency agreed with our recommendation and presented corrective action 

plans. The OIG considers the proposed corrective actions to be responsive. 

Recommendations 1a, 1b, and 1c are open with corrective actions pending. 

Appendix C contains the agency’s response to our draft report and planned 

actions to address our recommendations, as well as the OIG’s comments. Based 

on the agency’s response, we made a revision to the report.
15-P-0033 11

Chapter 3

Inefficient and Ineffective Property Storage 

and Management

The EPA did not establish effective and efficient controls for its property stored at 

its warehouse facilities. Specifically:

 The EPA did not timely excess or dispose of property at 13 percent

(one of eight) of the facilities reviewed. 

 The EPA did not sufficiently utilize warehouse space to store property at 

38 percent (three of eight) of the facilities reviewed. 

 Warehouses unnecessarily stored items that were readily available for 

purchase locally or did not fulfill an immediate need at 50 percent

(four of eight) of the facilities reviewed.

 The EPA did not prevent the unauthorized use of government property at 

25 percent (two of eight) of the facilities reviewed.

The EPA did not have effective controls to ensure efficient use of its property. 

As a result, the EPA has spent or is planning to spend almost $50 million

unnecessarily on the storage and upkeep of property. The agency spent at least 

$171,658 on property it ended up giving away because there was no use for it.

In total, we calculated that potential monetary benefits totaling about $8.9 million 

have been or can be achieved by the EPA through improved warehouse 

management. This will contribute toward the health of our environment by not 

storing unnecessary items that can be recycled, identifying opportunities to 

consolidate and dispose of existing property, optimizing the performance of the 

agency’s real-property portfolio, and reducing associated environmental impacts.

Better Property Storage and Management Needed

The Federal Property and Administrative Services Act of 1949 requires that an 

agency must continuously survey property under its control to determine what 

excess property is, and then promptly report such property to GSA’s 

Administrator. The act also requires that an agency transfer or dispose of such 

property as promptly as possible, and make reassignments of property among 

activities within the agency when such property is determined to be no longer 

required for the purposes for which it was purchased. 

Executive Order 13514, Federal Leadership in Environmental, Energy, and 

Economic Performance, states: 

It is therefore the policy of the United States that Federal agencies

increase energy efficiency; measure, report, and reduce their

greenhouse gas emissions from direct and indirect activities.
15-P-0033 12

This Executive Order also states: 

The head of each agency shall when adding assets to the agency’s 

real property inventory, identifying opportunities to consolidate 

and dispose of existing assets, optimize the performance of the 

agency’s real-property portfolio, and reduce associated 

environmental impacts.

OMB Memorandum M-12-12 requires that agencies make efficient use of the 

government’s real estate assets. OMB Management Resources Memorandum No. 

2010-07, dated July 1, 2010, states that agencies must develop plans to eliminate 

lease arrangements that are not cost effective, consolidating or co-locating common 

asset types such as warehouses. OMB Management Procedures Memorandum No.

2013-02, dated March 14, 2013, states that each agency should work 

collaboratively with other agencies and GSA to find opportunities for smarter space 

usage through co-locations and consolidations. OMB Circular A-123 and GAO’s

Standards for Internal Controls in the Federal Government state that the agency 

head must establish controls that reasonably ensure that funds, property and other 

assets are safeguarded against waste, loss, unauthorized use or misappropriation. 

Untimely Excess or Disposition of Property

The EPA did not timely excess, surplus and dispose of property such as tables, 

chairs, sofas, refrigerators, lamps, televisions, VCRs and computers stored at the 

Landover warehouse. This occurred because the EPA did not implement its 

policies to excess and dispose of property. Additionally, the agency did not

require its contractors to inventory non-accountable property, so it was unable to 

report property stored and thus maximize usage of its property. As a result of this 

audit, the EPA inventoried personal property at the Landover warehouse and 

provided this information to the RTP office. RTP officials were planning to 

purchase approximately $90,000 of furniture and supplies and they avoided doing 

so by using items from the Landover warehouse.

Surplus items in the Landover warehouse as of June 2013 (right) and some of those same items in 

November 2013 (left). (EPA OIG photos)
15-P-0033 13

The EPA did not effectively implement an agencywide accessible database, 

website or report to timely inform potential users of available property and avoid 

unnecessary spending. As a result, the EPA does not know what property is under 

its control and cannot ensure efficient use of EPA property stored.

Better Utilized Space to Store Property Needed

The EPA did not efficiently and effectively utilize space to ensure sufficient 

storage space usage at the Landover and V Street warehouses. The OIG observed 

rows of empty shelves at the Landover and V Street facilities. The OIG concluded 

that the EPA did not perform a study to assess the actual usage of warehouse 

space to determine whether consolidation of the similar Landover and V Street 

warehouses within close proximity to each other would achieve greater 

efficiencies, as they are both located in the Washington, D.C., area. The OIG 

concluded that the agency could save up to $360,000 annually through combining 

these locations.

As a result of our prior Landover report, the agency returned to GSA three of its 

five leased warehouse bays at the Landover warehouse. With this space reduction, 

the agency began to realize savings of over $2.2 million. Additionally, the agency

saved approximately $1.1 million by not using a warehouse management 

contractor during the course of this audit. 

Empty space in the V Street (left) and Landover (right) warehouses. (EPA OIG photos)

Unnecessarily Stored Items

The EPA unnecessarily stored items in selected warehouses/storage facilities that 

were readily available for purchase locally or did not fulfill an immediate need.

The EPA stored in the Landover, V Street, RTP, and Cincinnati warehouses 

purchased items such as refrigerators, air conditioners, copying paper, computers, 

computer accessories and toners that could have been purchased locally without 

the storage and/or did not satisfy an immediate need. Several refrigerators had 

been in the warehouse dating back to 2007. The EPA unnecessarily spent money 

to purchase and then store ceiling and flooring tiles and furniture it ended up 
15-P-0033 14

giving away because it did not have a use for these items. As a result of this audit, 

over $34,000 worth of ceiling tiles were transferred from the EPA’s Landover 

warehouse to a state agency. Also, over $137,000 worth of furniture from the 

Landover warehouse was transferred from the EPA to another federal agency. 

The EPA stored publications in the Cincinnati warehouse that exceeded demand

by 6 years. This occurred because the EPA’s inventory management belief is that 

it is better to have more-than-enough products on hand than to try to manage with 

just the amount of stock needed (a culture of print-store-ship rather than print then 

ship). The EPA staff seemed to indicate an attitude of “let’s store all items 

regardless,” instead of “let’s store items that we can control.” In addition, there 

were no policies to prevent long-term storage of items acquired by the EPA in an 

excess amount or that did not satisfy an immediate need. As a result, the EPA did 

not communicate costs associated with storing property, hindering effective 

management decisions for warehouse and property management.

 

Toners stored at V Street (upper left), brown envelops at Landover that are available locally 

and not fulfilling an immediate need (upper right), a 6-year supply of publications in

Cincinnati (lower left), and refrigerators in Landover (lower right). (EPA OIG photos)

Unauthorized Use of Space

The EPA did not establish effective controls to prevent the unauthorized use of 

government space. The EPA contractors at the Landover warehouse engaged in 

unauthorized activities such as using hidden personal spaces that included such 
15-P-0033 15

items as televisions and exercise equipment. The EPA contractors at the Woburn, 

Massachusetts, warehouse engaged in unauthorized activities such as having 

personal packages received at the EPA warehouse, storing and potentially using 

exercise equipment and bicycle repair equipment, and storing personal sleeping 

bags in vacant spaces. The OIG concluded one reason this occurred was because 

the EPA did not perform a study to assess the operational warehouse business 

hours that may have allowed for unauthorized use of warehouse space. Also, the 

unauthorized use of property existed because the EPA did not implement 

procedures to periodically monitor property management operations. In total, the 

agency paid contractors involved in the unauthorized use of space in Landover 

and Woburn $1.6 million per year—$1.1 million at Landover and $500,000 at 

Woburn.

 

Exercise equipment at the Woburn warehouse (upper left) and Landover warehouse (upper 

right),televisions for personal use at the Landover warehouse (lower left), and a bike repair 

toolbox at the Woburn warehouse (lower right). (EPA OIG photos)

Conclusion

The EPA’s actions based on OIG findings have helped the agency avoid millions 

of dollars in costs and could contribute to more savings and cost avoidances in the 

future. The EPA has already taken the following actions that represent monetary 

benefits of more than $3.5 million. Specifically, the agency:

 Transferred $34,560 worth of ceiling tiles to a state agency. 

 Transferred $137,098 of unused furniture to another federal agency.
15-P-0033 16

 Avoided $90,000 in potential purchases at RTP by using excess items 

from the Landover warehouse.

 Avoided costs of approximately $443,000 annually by excessing, 

disposing of and transferring usable property at the Landover warehouse 

to other users, thus releasing three bays at that warehouse. Based on a 

5-year GSA lease, this cost avoidance will total approximately 

$2.2 million.

 Saved $1.1 million by avoiding warehouse operational costs it had been 

paying and canceling the Landover warehouse management contract.

In addition, the EPA could realize additional potential lease savings and 

reductions in contract costs to oversee leased space. These potential cost 

avoidances could total as much as $5.4 million. Specifically:

 In our early warning report about the Cincinnati warehouse, we reported 

that the EPA is storing excessive publications. If the EPA reduced this 

warehouse space by half, it could annually avoid lease costs up to 

$250,700 (50 percent of the total lease cost of $501,400) plus up to 

$464,000 in management contract costs. Based on a 5-year lease, the cost 

avoidance could amount to about $3.6 million. 

 The V Street and Landover warehouses have unused spaces that, if 

combined, would avoid up to $359,200 in lease costs annually. This would 

amount to $1.8 million during a 5-year lease period.

Potential monetary benefits totaling about $8.9 million have been or can be 

achieved by the EPA through improved warehouse management. 

Recommendations

We recommend that the Assistant Administrator for Administration and 

Resources Management:

2. Perform an annual assessment of EPA warehouses and storage facilities on:

a. Operational hours needed by contractors to efficiently and 

effectively manage property and make any needed adjustments to 

management contracts. 

b. Used and unused square feet to aggressively consolidate storage of 

personal property located within the same city or metropolitan area.

c. Annual cost associated with storing each property item to assess 

whether storage is needed.
15-P-0033 17

3. Hold management and staff accountable for timely transfer or disposal of 

excess personal property according to the agency personal property policy 

and procedures manual.

4. Adopt new technologies, concepts and strategies that would generate 

inventory efficiencies in terms of storage, shipment and filling orders that 

reduce inventory levels and lower costs. 

5. Update agencywide policy to require the agency property staff to record 

and track non-accountable property in the existing national property 

management database, or accessible website, to maximize the re-use of 

property before making new purchases. 

6. Update agencywide policy to prevent long-term storage of personal 

property beyond a year that does not satisfy an immediate need.

7. Update agencywide policy to require periodic unannounced visits to the 

warehouses/storage facilities to ensure there is no unauthorized use of 

government resources and space is used efficiently.

8. Require property supervisors to generate accountability reports that are

provided to top-level management that identify work done to monitor 

property and deficiencies, and ensure the recommended actions on the 

deficiencies will be taken.

9. Train staff on best practices for inventory and storage to develop cultures, 

practices and attitudes to ensure that personal property items are controlled 

to prevent unnecessary storage.

Agency Comments and OIG Evaluation

The agency agreed with our recommendations and presented corrective actions. 

For Recommendations 3 and 6 we consider the proposed corrective actions to be 

responsive and the recommendations closed. For Recommendations 2, 4, 5, 7, 8, 

and 9, we consider the proposed corrective actions to be responsive and open with 

corrective actions pending.

Appendix C contains the agency’s response to our draft report and planned 

actions to address our recommendations, as well as the OIG’s comments.
15-P-0033 18

Status of Recommendations and 

Potential Monetary Benefits

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

1 10 Update EPA policies and contracts to require:

a. An inventory of non-accountable property 

and all electronics-type property in addition 

to accountable and sensitive property. 

b. The EPA to use the same inventory 

management system for all property, 

including courtesy-stored items along with 

other personal property in the warehouses. 

c. The EPA to reconcile annual physical 

inventory counts against its inventory system 

records for all personal property.

O

O

O

Assistant Administrator 

for Administration and 

Resources Management

12/31/14

12/31/15

5/31/15

2 16 Perform an annual assessment of EPA 

warehouses and storage facilities on:

a. Operational hours needed by contractors to 

efficiently and effectively manage property 

and make any needed adjustments to 

management contracts. 

b. Used and unused square feet to aggressively 

consolidate storage of personal property 

located within the same city or metropolitan 

area.

c. Annual cost associated with storing each 

property item to assess whether storage is 

needed.

O

O

O

Assistant Administrator 

for Administration and 

Resources Management

5/31/15

5/31/15

5/31/15

$2,200

$1,100

$3,600

$1,800

3 17 Hold management and staff accountable for timely 

transfer or disposal of excess personal property 

according to the agency personal property policy 

and procedures manual.

C Assistant Administrator 

for Administration and 

Resources Management

9/17/14

4 17 Adopt new technologies, concepts and strategies 

that would generate inventory efficiencies in terms 

of storage, shipment and filling orders that reduce 

inventory levels and lower costs.

O Assistant Administrator 

for Administration and 

Resources Management

6/30/15

5 17 Update agencywide policy to require the agency 

property staff to record and track non-accountable 

property in the existing national property 

management database, or accessible website, to 

maximize the re-use of property before making new 

purchases.

O Assistant Administrator 

for Administration and 

Resources Management

12/31/15 $34

$137

$90

6 17 Update agencywide policy to prevent long-term 

storage of personal property beyond a year that 

does not satisfy an immediate need.

C Assistant Administrator 

for Administration and 

Resources Management

9/17/14
15-P-0033 19

RECOMMENDATIONS

POTENTIAL MONETARY 

BENEFITS (in $000s)

Rec. 

No.

Page 

No. Subject Status1 Action Official

Planned 

Completion 

Date

Claimed 

Amount

Agreed-To 

Amount

7 17 Update agencywide policy to require periodic 

unannounced visits to the warehouses/storage 

facilities to ensure there is no unauthorized use of 

government resources and space is used 

efficiently.

O Assistant Administrator 

for Administration and 

Resources Management

11/30/15

8 17 Require property supervisors to generate 

accountability reports that are provided to top-level 

management that identify work done to monitor 

property and deficiencies, and ensure the 

recommended actions on the deficiencies will be 

taken.

O Assistant Administrator 

for Administration and 

Resources Management

5/31/15

9 17 Train staff on best practices for inventory and 

storage to develop cultures, practices and attitudes 

to ensure that personal property items are 

controlled to prevent unnecessary storage.

O Assistant Administrator 

for Administration and 

Resources Management

11/30/15

1 O = Recommendation is open with agreed-to corrective actions pending.

C = Recommendation is closed with all agreed-to actions completed.

U = Recommendation is unresolved with resolution efforts in progress.
15-P-0033 20

Appendix A

Details on Noteworthy Achievements

Date in 2013 Source of Memo Achievements Noted

May 23 Deputy 

Administrator

At the Landover warehouse, the agency indicated it re-secured the 

facility, inventoried and catalogued all items, marked surplus 

furniture, drafted new standard operating procedures for 

maintaining the warehouse, implemented changes to ensure safe 

handling of government passports, initiated an investigation by the 

Breach Evaluation Team to evaluate concerns with safeguarding 

personally identifiable information, commenced a review of 

records, began a review of EPA personnel to determine if 

disciplinary action is appropriate, and ordered an agencywide 

review of all warehouses and storage facilities. 

June 26 Assistant 

Administrator, 

OARM

The agency indicated it completed an evaluation of the handling of 

personally identifiable information, completed new standard 

operating procedures, required a review of all EPA warehouse and 

storage facility operations nationwide, awarded an interim labor 

services contract to provide warehouse operations support, issued 

a 120-day notice to GSA to release three bays or almost 30,000 

square feet of space at the Landover warehouse, implemented 

management controls that will ensure appropriate oversight of the 

warehouse as well as the contractor and federal staff assigned to 

the warehouse, ensured improved passport control procedures are 

being implemented, and determined the musical instruments at the 

warehouse were acquired at no cost and surplused in June.

September 30 Assistant 

Administrator, 

OARM

The agency indicated it completed updates to the warehouse 

recordkeeping, conducted records management training, 

developed security plans for the Landover warehouse perimeter 

and interior spaces, corrected all GSA infrastructure-related safety 

findings, and evaluated all onsite documents potentially containing 

personally identifiable information and identified and destroyed

documents containing personally identifiable information.

November 22 Deputy 

Administrator

The Woburn warehouse contractor notified the EPA that it 

terminated employees involved in the unauthorized use of its 

Region 1 storage space, created a new quality control plan, 

increased site visits and inspections, hired a new employee to 

service the warehouse, and revised the employee manual. The 

EPA reviewed the contract for possible termination, established 

more surveillance of contractor performance, did a follow-up 

inspection, and made recommendations for improvement. 

December 20 Deputy 

Administrator

Reported the results of nationwide, unannounced inspections of all 

warehouses and storage facilities. A few minor issues were 

detailed, such as noting for one field office that equipment and 

supplies were not well organized. In another location, a need for 

seismic bracing was noted. Locations were reviewed for standard 

operating procedures, health and safety standards, personally 

identifiable information and facility security, and equipment and 

inventory located there. 

Source: OIG analysis.
15-P-0033 21

Appendix B

Summary on Facilities Reviewed

OIG analysis from EPA-provided data.

Kenwood Warehouse & Distribution Center, Blue Ash, Ohio

 Use: Warehouse/ Storage

 Contractor Duties: Property and Transportation Management Support Service.

 Publications management including call center and warehouse management.

Conditions: Did not track all electronic property items, did not maintain annual physical 

inventories of personal property, did not sufficiently utilize warehouse space, and unnecessarily 

stored items that were readily accessible locally or did not fulfill an immediate need. 

Ardwick Industrial Plaza, Landover, Maryland

Use: Warehouse/ Storage

Contractor Duties: Warehouse operations support, labor support services.

Conditions: Did not track all electronic property items, did not maintain annual physical 

inventories of personal property, did not sufficiently utilize warehouse space, unnecessarily stored 

items that were readily accessible locally or did not fulfill an immediate need, and did not establish 

effective controls to prevent the unauthorized use of government resources.
15-P-0033 22

Grand Slam Building, Durham, North Carolina

Use: Laboratory/ Warehouse

Contractor Duties: Warehouse and mailroom services

 

Conditions: Unnecessarily stored items that were readily accessible locally or did not fulfill an 

immediate need.

Addison Training & Conference Center, Addison, Texas 

Use: Use: Warehouse/ Storage

Con Contractor Duties: Warehouse management and equipment maintenance services

Conditions: None specific to this location. 
15-P-0033 23

United Industrial Distribution Warehouse, Washington, D.C.

Use: Warehouse/ Storage

Contractor Duties: Warehouse inventory and property control management

Conditions: Inventoried courtesy items in a separate and manual inventory system, provided

independent oversight over contractor-controlled annual inventories, did not sufficiently utilize 

warehouse space, and unnecessarily stored items that were readily accessible locally or did not 

fulfill an immediate need.

Federal Center South Warehouse, Seattle, Washington 

Use: Warehouse/ Storage

No Contractor

Conditions: None specific to this location. 
15-P-0033 24

222 West Cummings Park Warehouse, Woburn, Massachusetts 

 Use: Warehouse, Storage

 Contractor Duties: Warehouse operations, equipment maintenance

Facility building

not pictured

Conditions: Did not establish effective controls to prevent the unauthorized use of government 

resources.

Terminal Annex Federal Building, Dallas, Texas 

 Use: Warehouse, Lab Storage

 No Contractor

Conditions: None specific to this location. 
15-P-0033 25

Appendix C

Agency Response to Draft Report

September 17, 2014

MEMORANDUM

SUBJECT: Response to Office of Inspector General Draft Audit Report No. OA-FY13-0248

EPA Needs Better Management of Personal Property in Warehouses, dated 

August 11, 2014.

FROM: Nanci E. Gelb, Acting Assistant Administrator

Office of Administration and Resources Management

TO: Kevin Christensen, Acting Assistant Inspector General 

Office of Audit

Thank you for the opportunity to review your draft report. The Office of Administration and 

Resources Management concurs with your recommendations and has included suggested 

adjustments to some of the recommendation language. Attachment 1 lists your recommendations 

and our responses.

OARM manages and operates three warehouses located in Landover MD, Cincinnati OH, and 

Research Triangle Park NC. Attachment 2 lists all EPA warehouses and their locations most 

which are operated by EPA regions and programs. OARM will issue guidance to EPA Senior 

Resource Officials implementing your recommendations related to their warehouse operations.

 

If you have any questions regarding our response, please contact Stacey Dey Foy, Acting 

Director, Facilities Management and Services Division, at (202) 564-2030.

Attachments

cc: Assistant Regional Administrators

Ramona Trovato

Betsy Shaw

Barry Breen 

James Woolford 

Donna Vizian

John Showman

Brandon McDowell

Vaughn Noga

Maryann Petrole

Steve Blankenship

Rick Carter

Pete Johnson

Stacey Dey-Foy

Yvette Jackson

Mike Davis
15-P-0033 26

OARM Response to Draft OIG Report EPA Needs Better Management of Personal 

Property in Warehouses 

Project No. OA-FY13-0248 Issued August 11, 2014

OIG Recommendation 1: Update EPA policies and contracts to require: 

a. An inventory of non-accountable property and all electronics-type property in 

addition to accountable and sensitive property.

b. The EPA to use the same inventory management system for all property, including 

courtesy-stored items along with other personal property in the warehouses.

c. The EPA to reconcile annual physical inventory counts against its inventory system 

records for all personal property. 

OARM recommends removing the word “contracts” from recommendation 1. OARM 

cannot update contracts administered by the regions and programs related to warehouse 

operations. Making this adjustment to the recommendation will allow OARM to focus 

on updating policy and enable successful implementation of the recommendations.

OIG Response: OIG agrees to remove “contracts” from the recommendation so that 

the recommendation reads, “Update EPA policies to require....”

1a. Concur with updating policy. OARM will issue policy guidance for warehouses that 

requires the tracking of non-accountable property and the accounting of all electronicstype property and all accountable and sensitive property. OARM will update its contracts 

accordingly for the three OARM operated warehouses (Landover, RTP, and Cincinnati).

The OARM is compliant with existing EPA Policy 4832 Personal Property Manual and 

the Property, Plant and Equipment (Reconciliation Requirements for Capital Property 

RMDSN 2540-11-T2) which requires reconciliation of annual physical inventory for all 

accountable personal property. Additionally, EPA 4832 identifies personal property as all 

property valued over $5,000 or considered sensitive (logical circuitry and or easily 

pilfered). This property is labeled and inventoried annually. Although tracking is required 

by the FMSD Landover Warehouse SOP, items that meet criteria of 41 CFR 102-36.220 

(expensed items, consumables, materials, supplies, etc.) are not reportable. All 

accountable property is inventoried annually by September 30th. 

Estimated completion date: December 31, 2014.

OIG Response: 1.a. The agency concurred and established planned completion dates

for the intended corrective action. The OIG considers the proposed corrective action to 

be responsive and the recommendation is open with corrective action pending.
15-P-0033 27

1b. Concur with updating policy. OARM will issue policy guidance which requires all 

property in warehouses be recorded in the agency asset management system. The agency 

asset management system will be the inventory management system for all property.

Estimated completion date: December 31, 2015.

OIG Response: 1.b. The agency concurred and established planned completion dates

for the intended corrective action plan. The OIG considers the proposed corrective 

action to be responsive and the recommendation is open with corrective action 

pending.

1c. Concur. While there is already an existing requirement to reconcile physical 

inventory counts for accountable personal property annually, OARM will strengthen EPA 

Policy 4832 Personal Property Manual by requiring warehouse custodians / Senior 

Resource Officials to perform an annual certification of non-accountable property 

residing in those warehouses.

Estimated completion date: May 31, 2015.

OIG Response: 1.c. The agency initially responded on September 17, 2014. 

However, the OIG had concerns with the agency’s response. These concerns were 

resolved in the Exit Conference and a subsequent meeting. The agency submitted a 

modified response for this recommendation on October 30, 2014. The agency 

concurred and noted the corrective action was completed. The OIG considers the 

completed corrective action to be responsive and the recommendation is open with 

corrective action pending.

OIG Recommendation 2: Perform an annual assessment of EPA warehouses and 

storage facilities on:

a. Operational hours needed by contractors to efficiently and effectively manage 

property and 

 make any needed adjustments to management contracts.

b. Used and unused square feet to aggressively consolidate storage of personal property 

located within the same city or metropolitan area. 

c. Annual cost associated with storing each property item to assess whether storage is 

needed. 

2a. Concur. It is important that EPA manages its warehouses efficiently, appropriately 

and according to law. OARM will issue guidance requiring EPA Senior Resource 

Officials to assess annually the operations of their warehouses to efficiently and 

effectively manage them and to make needed adjustments to their contracts as necessary.

Estimated completion date: May 31, 2015.
15-P-0033 28

OIG Response: The agency concurred and established planned completion dates for 

the intended corrective action. The OIG considers the proposed corrective action to be 

responsive and the recommendation is open with corrective action pending.

2b. Concur. OARM will issue guidance requiring EPA Senior Resource Officials to 

assess annually used and unused square feet to consolidate warehouse space and the 

storage of personal property located within the same city or metropolitan area.

Estimated completion date: May 31, 2015.

OIG Response: The agency concurred and established planned completion dates for 

the intended corrective action. The OIG considers the proposed corrective action to be 

responsive and the recommendation is open with corrective action pending.

2c. OARM has determined that the costs of storage and the need to store property at 

warehouses are based on the warehouse mission. OARM concurs with providing 

guidance to EPA Senior Resource Officials to annually assess the warehouses and the 

need to store property items to find costs savings and efficiencies in warehouse 

operations.

Estimated completion date: May 31, 2015.

OIG Response: The agency concurred and established planned completion dates for 

the intended corrective action. The OIG considers the proposed corrective action to be 

responsive and the recommendation open with corrective action pending.

OIG Recommendation 3: Hold management and staff accountable for timely transfer 

or disposal of excess personal property according to the agency personal property 

policy and procedures manual. 

3. Concur. The current Property Bulletin 14-004 Property Timelines and Deadlines 

addresses transaction times and accountability for timely transfer or disposal of personal 

property.

Property management officers and custodial officers are trained on timelines for the 

timely transfer or disposal of personal property and are accountable for adherence to 

these rules. 

Estimated completion date: Completed

OIG Response: The agency concurred and noted the corrective action was 

completed. The OIG considers the completed corrective action to be responsive and 

the recommendation is considered closed.
15-P-0033 29

OIG Recommendation 4: Adopt new technologies, concepts and strategies that would 

generate inventory efficiencies in terms of storage, shipment and filling orders that 

reduce inventory levels and lower costs. 

4. Concur. OARM will be implementing a new property management system and

providing guidance on incorporating emerging technologies along with best practices to 

generate efficiencies and enhanced internal controls. 

Estimated completion date: June 30, 2015

OIG Response: The agency concurred and established a planned completion date for 

the intended corrective action. The OIG considers the proposed corrective action to be 

responsive and the recommendation is open with corrective action pending.

OIG Recommendation 5: Update agency wide policy to require the agency property 

staff to record and track non-accountable property in the existing national property 

management database, or accessible website, to maximize the re-use of property before 

making new purchases. 

 

5. Concur. The agency property management system will be designated as the inventory 

management system for all property. 

Estimated completion date: December 31, 2015.

OIG Response: The agency concurred and established planned completion dates for 

the intended corrective action. The OIG considers the proposed corrective action to be 

responsive and the recommendation is open with corrective action pending.

OIG Recommendation 6: Update agency wide policy to prevent long-term storage of 

personal property beyond a year that does not satisfy an immediate need. 

6. Concur. This recommendation has been completed. OARM produced Bulletin 14-

0014 dated January 8, 2014, which addresses long-term storage. Long-term storage of 

property should not be determined by immediate need, but rather by whether an item 

which will be needed in the future is readily available from outside sources, or whether it 

is more cost effective to store the item for future use.

Estimated completion date: Completed
15-P-0033 30

OIG Response: OARM informed OIG that the correct bulletin in its response should 

be Bulletin 14-004. The agency concurred with the recommendation and indicated that 

the corrective action was completed. The OIG considers the completed corrective 

action to be responsive and the recommendation is closed. 

OIG Recommendation 7: Update agency wide policy to require periodic unannounced 

visits to the warehouses/storage facilities to ensure there is no unauthorized use of 

government resources and space is used efficiently. 

7. Concur. OARM will issue policy guidance requiring EPA Senior Resource Officials to 

conduct periodic unannounced visits to warehouses to guard against unauthorized use of 

government resources. 

Estimated completion date: November 30, 2015. 

OIG Response: The agency concurred and established planned completion dates for 

the intended corrective action. The OIG considers the proposed corrective action to be 

responsive and the recommendation is open with corrective action pending.

OIG Recommendation 8: Require property supervisors to generate accountability 

reports that are provided to top-level management that identify work done to monitor 

property and deficiencies, and ensure the recommended actions on the deficiencies will 

be taken. 

 

8. Concur. While there is already an existing requirement to reconcile physical 

inventory counts for accountable personal property annually , OARM will strengthen 

EPA Policy 4832 Personal Property Manual by requiring warehouse custodians / Senior 

Resource Officials to perform an annual certification of non-accountable property 

residing in those warehouses. 

Estimated completion date: May 31, 2015

OIG Response: The agency initially responded on September 17, 2014. However, the 

OIG had concerns with the agency’s response. These concerns were resolved in the 

Exit Conference and a subsequent meeting. The agency submitted a modified response 

for this recommendation on October 30, 2014. The agency concurred and noted the 

corrective action was completed. The OIG considers the completed corrective action

to be responsive and the recommendation is considered closed.

 
15-P-0033 31

OIG Recommendation 9: Train staff on best practices for inventory and storage to 

develop cultures, practices and attitudes to ensure that personal property items are 

controlled to prevent unnecessary storage. 

9. Concur. OARM will develop and disseminate best practices for inventory and storage 

to warehouse managers at Landover, RTP and Cincinnati and property management 

officers. OARM already conducts biannual training for custodial officers on best 

practices for accounting personal property and disposing excess property.

Estimated completion date: November 30, 2015.

OIG Response: The agency concurred and established planned completion dates for 

the intended corrective action. The OIG considers the proposed corrective action to be 

responsive and the recommendation is open with corrective action pending.
15-P-0033 32

Appendix D

Distribution

Office of the Administrator 

Assistant Administrator for Administration and Resources Management

Agency Follow-Up Official (the CFO)

Agency Follow-Up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs

Principal Deputy Assistant Administrator for Administration and Resources Management 

Director, Office of Policy and Resources Management, Office of Administration and 

Resources Management

Deputy Director, Office of Policy and Resources Management, Office of Administration and 

Resources Management

Director, Facilities Management and Services Division, Office of Administration and

Resources Management

Audit Follow-Up Coordinator, Office of Administration and Resources Management